Interpretation ID: nht67-1.18

DATE: 06/16/67

FROM: AUTHOR UNAVAILABLE: Robert M. O'Mahoney; NHTSA

TO: Peugeot, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: In answer to your letter of May 26, concerning Federal Motor Vehicle Safety Standards Nos. 208 and 210, your interpretation is correct: a four-passenger automobile (such an the Peugeot 404) must have two Type 2 seat belt assemblies for the front seat passengers if the windshield header is within the head impact area, two Type 1 or Type 2 sent belt assemblies for the front seat passengers if the windshied hender is not within the hand impact area, and two Type 1 seat belt assemblies for the rear seat passengers. However anchorages for Type 2 seat belt assemblies are required in the rear to enable the owner to install Type 2 seat belt assemblies should he desire to afford his rear seat passengers this means of protection.

May 26, 1967

Mr. O'Mahoney National Traffic Safety Agency United States Dept. of Commerce

Regarding our telephone conversation of May 26, I am in need of legal interpretation concerning Standards 208 and 210.

According to Standard 208, paragraph S3.1.1, Type 2 seat belt assembly should be installed in each outboard passenger car in the front seat position, including the windshield, within the impact area, which, in my mind includes the front seats only. Thus, the rear seats should have only Type 1 (lap belt).

From Standard 210, table 1, it seems to clearly indicate that we must have seal belt anchorages for a Type 2 seat belt in outboard seats in the rear, but it does not expressly state that the Type 2 seat belts should be installed in the outboard seats in the rear.

Would you kindly let me know if my interpretation is correct: on a 4-passenger car, we should have Type 2 seat belts in the front, Type 1 seat belts in the rear, but anchorages in the rear for Type 2 and Type 1 seat belts.

Thank you very much in advance for your reply.

Henri B. Combe Executive Vice President